May we hand out a summary instead of our lengthy notice of privacy practices, as long as we make the full notice available on request?
HIPAA Weekly Advisor, December 27, 2002
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Q: May we hand out a summary instead of our lengthy notice of privacy practices, as long as we make the full notice available on request?
A: The August 14, 2002, update to the final privacy rule recognizes the lengthiness of the privacy notice. Therefore, organizations are permitted to preface their notice with a summary. However, you must distribute the full notice; the summary does not replace it. A summary may help patients grasp the overall content of the notice, but it also adds more paper. It's entirely up to each organization whether to use one.
Direct treatment providers such as hospitals and doctors offices must hand out the full notice-with or without a summary-and obtain an acknowledgement of receipt in writing or make a good faith effort to obtain one.
Editor's note: Answered by Kate Borten, CISSP, president of The Marblehead Group, in Marblehead, MA, and excerpted from the December 2002 issue of Briefings on HIPAA.
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